The assessee failed to file returns for two years preceding the capital increase. The Tribunal held that unexplained capital accretion must be taxed under section 68.
The dispute concerned cancellation of IDS benefits due to non-payment. The Tribunal held that once IDS lapses, undisclosed income is taxable with mandatory penalty.
The Tribunal observed that the purpose of revision is to protect revenue interests. When no tax demand arises in consequential proceedings, the revision order no longer calls for adjudication.
ITAT Pune condoned an 897-904 day delay in appeals, holding the delay was unintentional and due to incorrect guidance. The case highlights that bona fide professional errors can justify condonation of delay.
The High Court held that the Tribunal exceeded its limited powers under Section 254(2) by recalling a final order on merits. Once the recall was struck down, the original favourable order stood automatically restored.
The Tribunal held that interest earned by a co-operative credit society from fixed deposits with co-operative banks remains deductible under Section 80P(2)(a)(i). Such interest is attributable to the business of providing credit facilities to members, even after the Totgars ruling.
The Tribunal observed that rejection of audited books and disallowance of labour charges must be backed by concrete defects. Purely ad-hoc estimations based on minimum wages were held improper.
The issue was whether advance money from a failed land deal could be taxed as income. The Tribunal held that without clear forfeiture, section 56(2)(ix) does not apply. Key takeaway: forfeiture is mandatory to tax advances.
The issue was whether a ₹3.05 crore disallowance under section 14A could stand without nexus to exempt income. The ITAT held that only a reasonable amount with clear linkage can be disallowed, capping it at ₹10 lakh.
The issue was whether section 153C could extend beyond six years without discovery of an undisclosed asset of ₹50 lakh or more. The ITAT held that in absence of such asset-based satisfaction, extended jurisdiction is invalid.
